Dismissing the appeal the Court held that No incriminating material found during search information and statements of three persons recorded by Investigation Wing. Assessee neither confronted with statements nor afforded opportunity to cross-examine persons whose statements were recorded. Notice was issued after six years. Order of Tribunal deleting the addition is affirmed. (AY. 2009-10)
PCIT v. K.R. Pulp and Papers Ltd (2025) 479 ITR 240 (Delhi)(HC)
S.147: Reassessment-After six years-Search and seizure-Cash credits-Share application money-Failure to issue notice-Reassessment based on suspicion-Deletion of addition by Tribunal is affirmed. [S. 68,133(6), 148, 260A]
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